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iii iiiiiiiiiiiu iii Concerns Re:?ardin~ the Second Draft of the State Drafted Discharge Permit for Battle Mountain Gold Prepared by CES ,._ ~~_Cj~p General Concerns about the Draft Discharge Permit: • The biggest concern is that there are no points of compliance or monitoring of water quality for the second discharge point. And there is ina~ dec~:_ monitoring of groundwater flow; This means that pollutants could be isc arge m o e creek and the mine would not be in violation of their permit. • The seepage "window" (the area that has been defined as the second discharge point" has been drastically increased in the second draft of the permit. Please refer to attached "Map of the Seepage Window(s)". This map shows the original area defined as the window and the new area now defined ;is the window. Why has the area where pollutants can be discharged bee~z so drastically increased? Water Quality Concerns: • Levels of pollutants in Groundwater downgradient from the West Pit are much higher than levels of pollutants above the west pit. This indicates that the mine is discharging contaminants into the groundwater and that they are flowing downgradient towards the community. Please refer to the attached graph of "Groundwater Levels of Dissolved Manganese Above and Below the West Pit". In this graph levels of dissolved manganese from a well above the I~it and levels of dissolved manganese from a well below the pit were compared. The levels of Dissolved Manganese in the well below the mine's west pit are substantially higher. • Levels of Sulfate and TDS are also higher downgradient of the west pit, again indicating a discharge of contaminants into the groundwater. • Levels of Sulfate and Dissolved Manganese in the Rito Seco (surfa~;e water) are much higher below the mine than above the mine. Please refer to the attached graph "Dissolved Manganese Levels in the Rito Seco Above and Below the West Pit" This shows that there are discharges to the Rito Seco that are effecting water quality. Note that the levels of Dissolved mangane:+e below the mine do not once meet water quality standards. (The water quality :standard for manganese is .OS mg/l)